Deployer
Under the EU AI Act, a Deployer (previously referred to as the "User" in early drafts) is defined as any natural or legal person, public authority, agency, or other body using an AI system under its authority, except where the AI system is used in the course of a personal non-professional activity.
While the "Provider" creates the AI tool, the Deployer is the entity that actually implements it in a real-world context. For example, if a company buys an AI-powered recruitment tool to screen job applicants, that company is the Deployer. The regulation recognizes that risks often materialize not just in how a model is built, but in how it is used.
For High-Risk AI Systems, Deployers have specific operational obligations under Article 26, including:
- Appropriate Use: Taking technical and organizational measures to ensure the system is used in accordance with the instructions provided by the Provider.
- Human Oversight: Assigning competent, trained natural persons to oversee the AI system, ensuring they have the authority to intervene or stop the system if necessary.
- Input Data Relevance: Ensuring that the input data (the data fed into the system during operation) is relevant and sufficiently representative for the intended purpose, to prevent "garbage in, garbage out" scenarios or bias.
- Monitoring & Logs: continuously monitoring the system for anomalies and retaining automatically generated logs for at least six months (or longer, depending on sector-specific laws).
- Fundamental Rights Impact Assessment (FRIA): For specific deployers (such as public bodies or banks), conducting an assessment of how the system might impact fundamental rights before deployment.
- Informing Workers: Employers must inform workers and their representatives before putting a high-risk AI system into service in the workplace.
Strategic Distinction: The shift from "User" to "Deployer" clarifies the liability structure. The Provider is liable for the product's compliance (e.g., accuracy, safety testing), while the Deployer is liable for its usage (e.g., not using a medical diagnostic tool to grade student exams). Crucially, a Deployer can become a Provider if they make substantial modifications to the system or market it under their own name.

















